ES-CON ASSET MANAGEMENT Ltd. (hereinafter referred to as the Company) has established the following policy in response to the Principles for Customer-Oriented Business Operation published by the Financial Services Agency on March 30, 2017. Based on this policy, we will aim to contribute to the development of the economy and society through sound business operations, broadly establish trust from society, and provide high-quality services as a professional group.

1. Formulation and announcement of policy for customer-oriented business operations, etc.

The Company formulates and announces a clear policy for achieving customer-oriented business operations, and regularly checks the status of efforts related to this policy.

2. Pursuing the best interests of our customers

The Company maintains a high level of expertise and professional ethics and conducts business in good faith and fairness to its customers, striving to serve their best interests. In addition, the Company endeavors to establish such business operations as an integral part of its corporate culture.

The Company endeavors to secure stable earnings for ESCON JAPAN REIT Investment Corporation (hereinafter referred to as ESCON REIT) and maximize unitholder’s value through enhancing the price stability and liquidity of investment units by increasing the scale of assets, growing distributions, and increasing market capitalization.

・ Growth strategy
・ Financial highlights

3. Proper management of conflicts of interest

In regard to conflicts of interests in dealings with stakeholders, the Company accurately understands when there is such a possibility, and in such a case, the Company appropriately manages such conflicts of interests in accordance with laws, regulations, and internal rules.

Although ES-CON JAPAN's sponsor pipelines and the group's extensive know-how in management operations are utilized to the greatest possible extent, there is concern that conflicts of interest could arise between the client, the Company, and interested parties, etc. Therefore, we previously prevents transactions that could potentially cause conflicts of interests in accordance with laws, regulations, and internal rules, including the Rules on Transactions With Interested Parties.
Specific policies and operational systems are set forth in an attachment.

・ Reports related to the management system, etc.*
*Translation for reference purposes only. ESCON REIT has not published an English version of reports related to the management system, etc.

4. Clarification of fees, etc.

We provide information that enables customers to understand the details of the fees they pay to the Company, including the types of services they are paying for.

Regarding fees, etc. received by the Company, in addition to asset management fees linked to total assets, the Company has adopted a management fee structure linked to income before taxes. In this way, the management fee system has been devised to strengthen the link between the profits of the unitholders and those of the Company.

・ Investment corporation agreement*
*Translation for reference purposes only. ESCON REIT has not published an English version of investment corporation agreement.

5. Provision of important information in a way that is easy to understand

The Company provides accurate and easy-to-understand information to promote its customers' understanding.

In addition to disclosing information in accordance with laws and regulations in terms of transparency, the Company discloses all information that could potentially have a significant impact on customers' investment decisions in a timely and easy-to-understand manner, including the information set forth in the Securities Listing Regulations Pertaining to Real Estate Investment Trust Securities.

・ Press releases

*As the Company does not sell or recommend multiple financial products or services as a package, the Company does not fall under the category of “selling or recommending multiple financial products or services as a package” as described in Note 2 of Principle 5: "Provision of important information in a way that is easy to understand" of the Principles for Customer-Oriented Business Operation published by the Financial Services Agency on July 30, 2017.

6. Providing services suitable for our customers

The Company endeavors to understand the needs of its customers, and manages assets with those needs in mind.

In managing the assets of ESCON REIT, the Company aims to secure long-term stable earnings and maximize unitholder value by understanding the needs, etc. of its unitholders through IR activities.

・ IR Library
・ Financial results explanation video*1
*1 Translation for reference purposes only. ESCON REIT has not prepared an English version of its video.

*2 As the Company does not sell or recommend multiple financial products or services as a package, the Company does not fall under the category of “selling or recommending multiple financial products or services as a package” as described in Note 2 of Principle 6: "Providing services suitable for our customers" of the Principles for Customer-Oriented Business Operation published by the Financial Services Agency on July 30, 2017.

7. Framework for appropriate employee incentives, etc.

The Company endeavors to carry out appropriate business operations, such as actions to pursue the best interests of its customers, and compliance activities to ensure the proper management of conflicts of interest. In addition, we establish training and other appropriate incentive frameworks and governance systems for all officers and employees.

The Company understands the importance of its asset management business of ESCON REIT as the act of managing the funds of ESCON REIT's unitholders. The Company positions compliance as the most important management issue, and requires that its executives and employees recognize their responsibilities as investment management experts and comply with their duty of loyalty and duty of due care of a prudent manager at all times. As part of that process, we formulate an annual compliance program and endeavor to practice legal compliance.
In addition, we introduce an Investment Unit Ownership Program system to promote mutual interests between unitholders, the officers and employees of the Company, and sponsors, with the aim of improving ESCON REIT's unitholder value.

・ Status of the acquisition of qualifications by officers and employees